Subject: File No. S7-14-08
From: JOEL F. HOLMES JR., JR. CLU, ChFC
Affiliation: SOCIETY OF FINANCIAL SERVICE PROFESSIONALS

October 29, 2008

THERE WAS A FAMOUS WORLD WAR II GENERAL THAT WAS ASKED BY THE GERMANS TO SURRENDER AND HIS ANSWER WAS...NUTS...AND THAT IS MY ANSWER TO THIS PROPOSAL.

YOU SHOULD ASKED THE MILLIONS OF AMERICANS THAT LOST MONEY IN STOCKS AND THEIR 401K,S IF THEY WISHED THEY HAD THEIR MONEY IN FIXED OF FIXED INDEX ANNUITIES AND YOU WOULD GET A 100% RESPONSE YES.

SINCE YOU HAVE BEEN HAVING PROBLEMS REGULATING THE SECURITIES INDUSTRY I RECOMMEND YOU CONTINUE TO LET INSURANCE PRODUCTS BE REGULATED BY THE STATES.

"NUTS"